The OFAC sanctions lists are the SDN list and a set of non-SDN lists that OFAC publishes together as the Consolidated Sanctions List. The SDN list names parties whose assets are blocked, and the non-SDN lists name parties under narrower restrictions. If your business is in the US, both sets apply to the vendors you pay and the customers you invoice. This guide covers what each list does, how to search and download them, and what you have to do when you find a match.
What is OFAC and where does its power come from?
OFAC is the Office of Foreign Assets Control, part of the US Department of the Treasury. Its FAQ 1 describes the job:
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) administers and enforces economic and trade sanctions against targeted foreign jurisdictions and regimes, as well as individuals and entities engaging in harmful activity.
OFAC does not create sanctions on its own. Each program rests on statutes, presidential executive orders and OFAC regulations in 31 CFR chapter V. Two laws do most of the work.
- IEEPA, the International Emergency Economic Powers Act. OFAC's FAQ 1190 says the majority of its programs are issued under IEEPA. In plain words, section 1701 of the Act lets the President use these powers against an "unusual and extraordinary threat" that comes mostly from outside the US, once the President has declared a national emergency about that threat.
- TWEA, the Trading with the Enemy Act. This is the older law. Its core power, in 50 U.S.C. 4305, opens with the words "During the time of war." It still sits under some programs: OFAC's Cuba sanctions page lists sections 5 and 16 of TWEA among that program's legal authorities.
Other statutes back specific programs, but a small business rarely needs to know which one. What matters is the list a name sits on and the program tag attached to it.
Which lists does OFAC publish?
OFAC's FAQ 10 says that "aside from the SDN List, OFAC publishes and maintains other sanctions lists that have different prohibitions associated with them." In practice there are two sets:
- The SDN list. The Specially Designated Nationals and Blocked Persons List.
- The non-SDN lists. OFAC's Other OFAC Sanctions Lists page currently names six. OFAC's FAQ 422 says their data is published in "a single, consolidated data file (known as the Consolidated Sanctions List)."
| List | Short name | Who is on it | What it restricts |
|---|---|---|---|
| Specially Designated Nationals and Blocked Persons List | SDN | People, companies, groups, vessels and aircraft | Full blocking. US persons cannot deal with them, and their property in US hands is frozen. |
| Sectoral Sanctions Identifications List | SSI | Persons operating in sectors of the Russian economy | The specific dealings described in the directives attached to each entry |
| Foreign Sanctions Evaders List | FSE | Foreign persons who violated US sanctions on Iran, or who helped hide transactions for sanctioned persons | Transactions by US persons or within the US involving them. The list has been empty since 18 December 2025. |
| Non-SDN Palestinian Legislative Council List | NS-PLC | Members of the Palestinian Legislative Council elected on the slate of Hamas or another designated terrorist group, who are not on the SDN list | US financial institutions may reject transactions with them under General License 4 |
| List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions | CAPTA | Foreign banks and other financial institutions | Opening or keeping a US correspondent or payable-through account for them is banned or subject to strict conditions |
| Non-SDN Menu-Based Sanctions List | NS-MBS | Persons hit by a "menu" of sanctions chosen case by case | Sanctions that OFAC calls "less than full blocking," such as limits on certain goods or services |
| Non-SDN Chinese Military-Industrial Complex Companies List | NS-CMIC | Certain Chinese companies | Restrictions under statute or other authorities, including the executive order of 3 June 2021 on securities investments that finance certain Chinese companies |
CAPTA and NS-PLC deal with banks. For a business paying vendors in QuickBooks, the SDN list is the one to watch most closely. SSI and NS-CMIC entries can still matter if you trade with Russian or Chinese companies, so include the non-SDN lists in every search.
What is the SDN list, in short?
The SDN list is OFAC's main list. It names individuals, companies, groups, vessels and aircraft whose property is blocked. OFAC's FAQ 10 says US persons "are prohibited from engaging in transactions involving blocked persons wherever blocked persons are located." Companies owned 50 percent or more by blocked persons are blocked too, even when they are not named.
We cover entries, program tags, the 50 percent rule and how to read a search result in our guide to the OFAC SDN list.
What is the difference between blocking and non-SDN restrictions?
Blocking is a freeze. OFAC's FAQ 9 says blocked property may not be transferred or otherwise dealt in without OFAC authorization. For a business, that means you cannot pay, buy from, sell to or contract with an SDN. If their money reaches you, you hold it. You do not send it back.
A non-SDN listing is narrower. OFAC's FAQ 422 explains when a name goes on one of these lists instead:
However, when the treatment of sanctions targets is unique and stops short of the blocking treatment, these names will appear on the one of OFAC's non-SDN lists.
So each non-SDN entry bans something specific. An SSI entry restricts the dealings described in its directive. OFAC's SSI page says the directives "describe prohibitions on dealings with the persons identified." The only way to know what is banned is to read the entry and the directive or order it points to. If an entry is unclear, treat it as a stop and ask a sanctions lawyer before you pay.
How are country programs different from list-based sanctions?
Not every OFAC restriction comes from a list of names. FAQ 10 describes two kinds of program:
- Comprehensive sanctions. These "broadly prohibit most transactions involving the particular jurisdiction" and may also block that country's government. OFAC says they cover "both countries and certain geographic regions." This is what people mean by an embargo.
- Targeted, or list-based, sanctions. These hit specific persons linked to a country or an activity, such as terrorism or narcotics trafficking. The SDN list is the main tool.
The practical effect for a small business: a clean name search does not clear a deal with an embargoed place. A supplier based in a comprehensively sanctioned country can be off every list and still be off limits. Check the address and country on the vendor record as well as the name, and look up the program on OFAC's Sanctions Programs and Country Information page. That page currently lists 36 active programs.
How do you search all OFAC lists at once?
Use Sanctions List Search, OFAC's free web tool. FAQ 369 says it returns potential matches from both the SDN list and the Consolidated Sanctions List in one search. The List column on each result tells you which list the match is on.
The search form has a List filter with three options: All, SDN and Non-SDN. Leave it on All. You can also filter by type (individual, entity, vessel or aircraft), program, country, address and ID number.
The tool is for people searching one name at a time. FAQ 287 says it "should not be utilized by automated systems that are configured to continually run searches through the tool." For a step-by-step check of a QuickBooks vendor list, see how to screen QuickBooks vendors against the OFAC list.
Downloading the lists
If you want the data itself, OFAC publishes it through its Sanctions List Service. The file format FAQs say:
- CSV. FAQ 80 says the CSV file opens in Excel or any other spreadsheet program. This is the easiest file for a small business.
- XML, fixed-width and delimited files. FAQ 79 says these can be imported into many software programs.
- Detailed XML. OFAC's Advanced Sanctions Data Model format, with its own explanatory documentation.
- Delta file. FAQ 90 says OFAC offers a file of changes only, as part of the Sanctions List Service.
There is one set of files for the SDN list and one for the Consolidated list. Download both. FAQ 89 says the SDN and Consolidated lists are complete each time, so you can overwrite your old copy with the new one. You never need to stitch updates together.
How does OFAC announce list changes?
Every change appears on the Recent Actions page, with a date and a title naming the programs affected. FAQ 90 says OFAC records changes to the SDN list and other lists there "in human-readable form." The page also has an email sign-up.
Changes come often. Between 29 September and 9 October 2026, OFAC posted sanctions list updates on seven separate days. Those covered counter terrorism, counter narcotics, Iran, non-proliferation and transnational criminal organizations designations, plus removals.
A vendor you checked last quarter can be listed this week. Re-screen your vendors and customers after list updates, not only when you add them. Sanctions Clear, opening to QuickBooks Online and Xero users, will check your vendors and customers against the OFAC SDN and non-SDN lists, fetched every 6 hours, and keep a dated record of each check.
What do US businesses have to do?
OFAC's FAQ 11 says all US persons must comply. That covers US citizens and permanent residents anywhere, anyone in the US, and US-incorporated companies with their foreign branches. There is no size threshold, as we explain in do small businesses need OFAC screening.
When you find a confirmed match, the rules in 31 CFR part 501 set out what comes next:
- Stop the transaction. Do not pay, ship or invoice until you know what the listing restricts.
- Block or reject. If the party is an SDN and you hold their property, block it. If a transaction is banned but nothing is blocked, reject it.
- Report within 10 business days. Under 31 CFR 501.603, blocking reports "shall be filed within 10 business days from the date that property becomes blocked." Under 31 CFR 501.604, rejected transaction reports are due within 10 business days of the rejection. Reports go through the OFAC Reporting System.
- Report blocked property every year. If you still hold blocked property, 501.603 also requires an annual report, due by 30 September, covering what you held on 30 June.
- Keep records for 10 years. 31 CFR 501.601 requires records of each transaction subject to OFAC rules to be kept "for at least 10 years after the date of such transaction."
OFAC is one regulator among several. The UK, the EU and the UN each keep their own lists, and our guide to what a sanctions list is explains how they fit together.
